On January 31, 2022, the Tax Court issued the full opinion in TBL Licensing LLC v. Commissioner (158 T.C. No. 1). The primary issues presented in TBL Licensing LLC v. Commissioner were (a) whether the petitioner was required to recognize gain in the intangible property as a result of a reorganization, and (b) whether the reorganization was a disposition within the meaning of IRC § 367(d)(2)(A)(ii)(II). Background to TBL Licensing LLC v. Commissioner The deficiency